This office has recently completed an audit of Transportation Union GCA 687 under the Compliance Audit Program (CAP) to determine your organization’s compliance with the provisions of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). As discussed during the exit interview on July 22, 2015, the following problems were disclosed during the CAP. The matters listed below are not an exhaustive list of all possible problem areas since the audit conducted was limited in scope.

Reporting Violations

Failure to File Bylaws

The audit disclosed a violation of LMRDA Section 201(a), which requires that a union submit a copy of its revised constitution and bylaws with its LM report when it makes changes to its constitution or bylaws. GCA 687 amended its constitution and bylaws in 2007, but did not file a copy with its LM report for that year.

GCA 687 has now filed a copy of its constitution and bylaws.

Other Violations

The audit disclosed a violation of LMRDA Section 401(d), which requires that an intermediate body union hold an officer election at least every four years. GCA 687 held an election in January 2011 and then most recently in May 2015, which is beyond the four year requirement.

GCA 687 must hold its next election no later than May 2019.

Other Issues

The union reported bonding coverage of $75,000 on its 2014 LM-2 report. At GCA 687’s current level of assets and receipts, $75,000 would be an inadequate amount of bonding to comply with the law. During the audit it was established that the SMART-Transportation Division carries a blanket bond for it subordinate unions that covers ten percent of assets and receipts, which is in compliance with the law. In the future, please ensure that the correct amount of bonding is reported in item 14 of the LM-2 report.

I want to extend my personal appreciation to Transportation Union GCA 687 for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you make sure this letter and the compliance assistance materials provided to you are passed on to future officers. If we can provide any additional assistance, please do not hesitate to call.